Form 990-T Archives - TAX CONTROVERSY 360

Weekly IRS Roundup October 7 – October 11, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Oct 24, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 7, 2024 – October 11, 2024.

October 7, 2024: The IRS released Internal Revenue Bulletin 2024-41, which includes the following:

Notice 2024-69, which provides the inflation adjustment factor and reference price for the renewable electricity production credit under 45 of the Internal Revenue Code (Code) for calendar year 2024. The inflation adjustment factor and reference price are used to determine the availability and amount of the credit for electricity produced from qualified energy resources in the United States or its possessions.
Revenue Procedure 2024-36, which updates the requirements for substitute IRS Forms W-2c and W-3c by detailing the specifications for red-ink and black-and-white forms as well as the electronic filing procedures. The new guidelines emphasize the importance of conforming to these specifications to avoid penalties and ensure proper processing by the IRS and Social Security Administration.

October 7, 2024: The IRS issued final regulations, which qualify certain syndicated conservation easement transactions as “listed transactions,” requiring their disclosure on IRS Form 8886, Reportable Transaction Disclosure Statement, and Form 8918, Material Advisor Disclosure Statement, by certain participants and material advisors. These regulations aim to prevent the use of inflated appraisals to claim unwarranted tax deductions and are effective as of October 8, 2024.

October 7, 2024: The IRS reminded taxpayers that the deadline to file their 2023 federal income tax returns is October 15, 2024. However, taxpayers in combat zones, disaster areas, and those affected by the terrorist attacks in Israel have extended deadlines to file and pay their taxes.

October 7, 2024: The IRS issued proposed regulations, which clarify that entities entirely owned by Indian tribal governments will not be recognized as separate entities for federal tax purposes or be subject to federal income tax. The regulations also provide that these entities may receive the value of certain energy credits under the Inflation Reduction Act of 2022.

October 10, 2024: The IRS announced it is processing approximately 400,000 Employee Retention Credit claims and is working on expediting these claims while ensuring compliance and preventing improper payments.

October 10, 2024: The IRS announced that the projected gross tax gap, which reflects the difference between true tax liability and taxes paid on time, for tax year 2022 has increased to $696 billion. The IRS attributes this increase to economic growth rather than changes in taxpayer behavior.

October 11, 2024: The IRS issued Revenue Procedure 2024-39, which grants certain entities an automatic six-month extension to file IRS Form 990-T, Exempt Organization Business Income Tax Return (and proxy tax under Section 6033(e) of the Code), for making elective payment elections under Code § 6417. This relief aims to assist entities unfamiliar with the filing process and those facing electronic filing limitations.

October 11, 2024: The IRS [...]

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Weekly IRS Roundup January 15 – January 19, 2024

by Kevin Spencer, Evan Walters and Jeremy Kass | Jan 23, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 15, 2024 – January 19, 2024.

January 16, 2024: The IRS released Internal Revenue Bulletin 2024-3, which includes the following:

Notice 2024-10, which provides guidance on the corporate alternative minimum tax, including rules for determining the “adjusted financial statement income” of a US shareholder when a controlled foreign corporation pays a dividend and modifications to Notice 2023-64.
Proposed regulations, which provide guidance on the new Internal Revenue Code (Code) Section 45X advanced manufacturing production credit established by the Inflation Reduction Act of 2022 (IRA). This credit is intended to incentivize domestic production of certain green energy components.
Final regulations regarding penalty protections for de minimis errors on information returns and payee statements.

January 16, 2024: The IRS released transitional guidance under Code Section 60501 on reporting transactions involving the receipt of digital assets and clarified that at this time, digital assets are not required to be included when determining whether cash received in a single transaction (or two or more related transactions) meets the reporting threshold.

January 16, 2024: The IRS issued Revenue Ruling 2024-3, which provides the February 2024 applicable federal rates.

January 16, 2024: The IRS reminded taxpayers of their rights under the Taxpayer Bill of Rights, which includes 10 rights all taxpayers have any time they interact with the IRS. Those rights include privacy, confidentiality and the right to appeal an IRS decision in an independent forum.

January 17, 2024: The IRS announced the appointment of 12 new members to the Internal Revenue Service Advisory Council, a public forum that provides the IRS and agency leaders with feedback, observations and recommendations related to tax administration.

January 18, 2024: The IRS reached a major milestone in the implementation of key provisions in the IRA as more than 1,000 projects have now been registered through the new IRS Energy Credits Online tool.

January 18, 2024: The IRS alerted a limited group of tax-exempt organizations subject to unrelated business income tax that they will not be able to electronically file Form 990-T, Exempt Organization Business Income Tax Return, or Form 1120-POL, U.S. Income Tax Return for Certain Political Organizations, until March 17, 2024.

January 19, 2024: The IRS issued Notice 2024-20, which provides guidance on the qualified alternative fuel vehicle refueling property credit under Code Section 30C. The IRS intends to issue additional guidance via proposed regulations.

January 19, 2024: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Weekly IRS Roundup August 29 – September 2, 2022

by McDermott Will & Emery | Sep 6, 2022 | IRS Guidance, Tax Reform, Tax Refunds

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 29, 2022 – September 2, 2022.

August 29, 2022: The IRS released Internal Revenue Bulletin 2022-35, which highlights the following:

Revenue Ruling 2022-15: This revenue ruling provides interest rates for tax overpayments and underpayments for the fourth quarter, starting October 1, 2022. The new rates are as follows:
- Individuals: 6% per year, compounded daily, for both overpayments and underpayments
- Corporations: 5% for overpayments; 6% for underpayments
- Corporate overpayments for the portion exceeding $10,000:5%
- Large corporate underpayments: 8%

Revenue Ruling 2022-16: This revenue ruling provides the average annual effective interest rates on new loans under the Farm Credit System and also contains a list of the states within each Farm Credit System Bank territory.

Treasury Decision 9964: The IRS released final regulations, providing guidance to states wanting to inspect certain return information for the purpose of administering state laws related to tax-exempt organizations. The final regulations reflect changes to the Internal Revenue Code made by the Pension Protection Act of 2006.

August 29, 2022: The IRS announced that September is National Preparedness Month and urges everyone to develop or update their emergency plans, especially with hurricane season approaching and the ongoing threat of wildfires.

August 29, 2022: The IRS released Tax Tip 2022-132, highlighting the Security Summit’s summer series, Protect Your Client; Protect Yourself. Professionals from the IRS, state tax agencies and others in the tax industry joined forces for a five-week series focused on the fundamentals of data and information security.

August 30, 2022: The IRS released Tax Tip 2022-133, clarifying taxpayer obligations during a Chapter 13 bankruptcy.

August 31, 2022: The IRS announced that Edward Killen will become division commissioner of its Tax-Exempt and Government Entities (TE/GE) division, effective September 30, 2022. The current TE/GE Commissioner, Sunita Lough, is retiring. Chief Privacy Officer Robert Choi will replace Killen as deputy commissioner of TE/GE.

August 31, 2022: The IRS released COVID Tax Tip-134, reminding parents of refunds and tax credits they may be missing if they do not normally file a tax return.

August 31, 2022: The IRS asked for comments on Form 7205, which is used to claim deductions for energy-efficient commercial buildings. The IRS wants to standardize the procedures for claiming the deduction and invites comments by October 31, 2022.

September 1, 2022: The IRS released Tax Tip 2022-135, providing suggestions to tax professionals on ways to protect clients from identity theft.

September 2, 2022: The IRS issued a statement acknowledging that it released confidential information from Form 990-Ts, which should not have been made public. Form 990-T is a business tax return used by tax-exempt entities to report and pay income [...]

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